phdrea Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how phdrea ("phdrea," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "your," or "User") who access or use the phdrea website, mobile application, and all associated gaming and betting services (collectively, the "Platform").

phdrea takes data privacy seriously. We understand that Filipino players trust us with sensitive personal and financial information, and we are committed to handling that information responsibly, transparently, and in full compliance with applicable Philippine data privacy laws.

This Policy applies to all personal data processed by phdrea in connection with your use of the Platform, regardless of whether you are a registered member or a visitor. Please read this Policy carefully. If you do not agree with the practices described herein, you should discontinue your use of the phdrea Platform.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, phdrea acts as the personal information controller in respect of the personal data collected through the Platform. This means phdrea determines the purposes and means by which your personal data is processed.

Where phdrea engages third-party service providers to process personal data on its behalf, those providers act as personal information processors and are contractually bound to process data only in accordance with phdrea's instructions and applicable law.

3 Personal Data We Collect

phdrea collects the following categories of personal data from users of the Platform:

3.1 Identity and Contact Information

• Full legal name as it appears on your government-issued identification
• Date of birth (used to verify the 21+ age requirement)
• Residential address, including barangay, city or municipality, and province
• Email address and mobile phone number
• Government-issued identification numbers (e.g., PhilSys National ID, passport number, driver's license number)

3.2 Financial Information

• GCash or PayMaya mobile wallet account details (account name and number only)
• Bank account details for BPI, BDO, or Metrobank withdrawals (account name and number only)
• Transaction history, including deposit amounts, withdrawal amounts, and dates
• Source of funds declarations where required for KYC compliance

3.3 Gaming and Account Activity Data

• Account username and encrypted password
• Betting history, game participation records, and wagering patterns
• Bonus and promotion usage history
• Responsible gaming settings and self-exclusion records
• Customer support interaction records

3.4 Technical and Device Data

• IP address and approximate geolocation data
• Device type, operating system, and browser information
• Session duration, pages visited, and features used on the Platform
• Cookie identifiers and similar tracking data (see Section 8)

4 How We Collect Your Data

phdrea collects personal data through the following means:

• Registration: When you create a phdrea account, you provide identity, contact, and account information directly.
• KYC Verification: When you submit identity documents for account verification, phdrea collects the information contained in those documents.
• Transactions: When you make deposits or withdrawals, phdrea collects the financial information necessary to process those transactions.
• Platform Use: phdrea automatically collects technical and activity data as you use the Platform, including through cookies and similar technologies.
• Customer Support: When you contact phdrea's support team, we collect the information you provide in the course of that interaction.
• Third-Party Verification: phdrea may receive identity verification data from third-party KYC service providers engaged to assist with regulatory compliance.

5 How We Use Your Personal Data

phdrea uses the personal data it collects for the following purposes:

phdrea will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6 Legal Basis for Processing

phdrea processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and phdrea, including providing gaming services, processing transactions, and managing your account.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations, gaming regulations, and tax obligations.
• Legitimate Interests: Processing is necessary for phdrea's legitimate interests, including fraud prevention, platform security, and improving the quality of our services, provided those interests are not overridden by your rights and interests.
• Consent: For certain processing activities, such as sending marketing communications or using non-essential cookies, phdrea relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing and Disclosure

phdrea does not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

7.1 Service Providers

phdrea engages trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC verification providers, cloud hosting providers, and customer support platforms. These providers are contractually bound to process your data only on phdrea's instructions and in compliance with applicable data privacy laws.

7.2 Regulatory and Law Enforcement Authorities

phdrea may disclose personal data to Philippine government agencies, regulatory bodies, or law enforcement authorities where required by law or where phdrea has a good-faith belief that disclosure is necessary to comply with a legal obligation, protect the rights or safety of phdrea or its users, or investigate suspected fraud or illegal activity. This includes mandatory reporting to the Anti-Money Laundering Council (AMLC) as required under Philippine law.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of phdrea's assets, your personal data may be transferred to the acquiring entity. phdrea will notify affected users of any such transfer and the privacy practices of the acquiring entity prior to the transfer taking effect.

8 Cookies and Tracking Technologies

phdrea uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain session security, and gather analytics data. The following types of cookies are used:

8.1 Essential Cookies

These cookies are strictly necessary for the Platform to function. They enable core features such as user authentication, session management, and security. Essential cookies cannot be disabled without significantly impairing your ability to use phdrea.

8.2 Analytics Cookies

phdrea uses analytics cookies to understand how users interact with the Platform, including which pages are visited most frequently and where users encounter difficulties. This data is used in aggregated, anonymized form to improve the Platform's performance and usability.

8.3 Preference Cookies

Preference cookies allow phdrea to remember your settings and preferences, such as your preferred language and display settings, so you do not need to re-enter them each time you visit.

8.4 Marketing Cookies

With your consent, phdrea may use marketing cookies to deliver relevant promotional content about phdrea's games and offers. You may withdraw consent for marketing cookies at any time through your browser settings or the phdrea cookie preference center.

9 Data Security

phdrea implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the phdrea Platform
• Encryption of sensitive data at rest, including identity documents and financial information
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular security audits and vulnerability assessments of the Platform infrastructure
• Multi-factor authentication options for user accounts
• Automated fraud detection and suspicious activity monitoring systems
• Staff training on data privacy and security best practices

While phdrea takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phdrea will notify the National Privacy Commission and affected users in accordance with the requirements of the Data Privacy Act.

10 Data Retention

phdrea retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

Upon expiry of the applicable retention period, phdrea will securely delete or anonymize your personal data in accordance with its data disposal procedures, unless retention is required by a specific legal obligation or ongoing legal proceedings.

11 Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by phdrea:

• Right to be Informed: You have the right to be informed about how phdrea collects and processes your personal data, as described in this Policy.
• Right of Access: You have the right to request a copy of the personal data phdrea holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data phdrea holds about you.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phdrea's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on phdrea's legitimate interests.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe phdrea has violated your data privacy rights.

12 Children's Privacy and Age Restriction

The phdrea Platform is strictly intended for adults aged 21 years and above. phdrea does not knowingly collect personal data from individuals under the age of 21. The 21+ age requirement is enforced through age verification procedures during registration and KYC processes.

If phdrea becomes aware that personal data has been collected from a person under the age of 21, the relevant account will be immediately suspended, the data will be deleted as soon as practicable, and any deposits may be returned at phdrea's discretion in accordance with the Terms and Conditions.

13 Third-Party Links and Services

The phdrea Platform may contain links to third-party websites or integrate with third-party services such as payment providers. This Privacy Policy applies only to the phdrea Platform and does not cover the privacy practices of any third-party websites or services.

phdrea is not responsible for the privacy practices or content of third-party websites. When you navigate away from the phdrea Platform to a third-party site, you do so at your own risk and should review the privacy policy of that site before providing any personal information.

Third-party payment providers such as GCash, PayMaya, BPI, BDO, and Metrobank operate under their own privacy policies and data protection frameworks. phdrea recommends that you review those policies to understand how your payment data is handled by those providers.

14 Updates to This Privacy Policy

phdrea reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the features of the Platform. The date of the most recent revision is displayed at the top of this page.

When material changes are made to this Policy, phdrea will notify registered users via email or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of the phdrea Platform after the effective date of any revised Policy constitutes your acknowledgment of the changes.

phdrea encourages you to review this Privacy Policy periodically to stay informed about how your personal data is being protected. If you have any concerns about changes to this Policy, please contact our Data Protection Officer before continuing to use the Platform.

15 Contact Us and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or phdrea's handling of your personal data, please contact our Data Protection Officer:

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe phdrea has not handled your personal data in accordance with the Data Privacy Act of 2012. Information about the NPC and how to file a complaint is available through official Philippine government channels.

For responsible gaming concerns, including self-exclusion requests and gaming limit adjustments, please visit the Responsible Gaming page or contact our support team directly. phdrea treats all responsible gaming requests with the highest priority.